January 2026 Quarterly Training Resources
Information and resources from the January 2026 Quarterly Training, presented by the Charter Authorizer Support Initiative (CASI).Dependent Charter Schools
The January 2026 CASI Quarterly Training presented information on oversight requirements, as well as personnel and governance ramifications of being both authorizer and governing body of a dependent charter.
Disclaimer
The information contained on this page is provided as a reference only. Charter schools and chartering authorities are encouraged to review the laws and regulations and consult with their own legal counsel regarding the application to their specific situations.
Live Video Recording
CASI Quarterly Training, January 2026
(Video; 1:38:45) (Note: Portions of the video have been edited for length and content.)
Section Menu
- Definition
- Statistics
- Governance Considerations
- Operational Differences
- Financial Oversight Requirements
- Why Separate Finances Matter
- Additional Constraints for Locally Funded Charters
- Dependent vs. Independent Charter Schools Comparison
- Additional Resources
Definition
The term "dependent charter" doesn't actually appear in California Education Code (EC). These schools are typically created by the district or county, receive funding that passes through the district/county, and operate for most purposes as a school of the district. The governing board of a dependent charter is usually the authorizing board itself.
Statistics
According to the California Department of Education (CDE) 2025–26 Charter School Certification of Information, 286 of 1,249 charter schools (26 percent) are locally funded. The vast majority of these have the authorizing board serving as their governing board, with some using advisory councils or committees as well.
Governance Considerations
The key challenge is balancing the requirement in EC Section 47601 that charters "operate independently from the existing school district structure" when the charter's governing board is the authorizer board. Best practices include clear agenda management, convening/recessing procedures, and separate minutes to distinguish which "hat" the board is wearing.
Operational Differences
Charter staff are usually district/county office of education (COE) employees who may have limited charter school experience. Employee transfers are governed by collective bargaining agreements and petition language.
Financial Oversight Requirements
Despite the close relationship, the district/COE must still perform full fiscal oversight duties, as for any charter. Key requirements include:
- The Local Control and Accountability Plan (LCAP) must be presented separately (not part of district/COE)
- The charter must maintain independent fiscal operations
- Pass-through funding should be recorded separately, per EC Section 47651(a)(2)
Why Separate Finances Matter
Different demographics may affect funding calculations, and co-mingling makes tracking the dependent charter’s finances difficult. The charter school will be included in the district's audit with stratified sampling.
Additional Constraints for Locally Funded Charters
Dependent charter schools typically:
- Cannot form a 501(c)(3)
- May be restricted to district vendors
- Must use the same student information system
- Must follow district policies/procedures
- Must adhere to district salary schedules
- May have calendar restrictions.
Dependent vs Independent Charter Schools Comparison
Definition and Structure
| Aspect | Dependent Charters | Independent Charters |
|---|---|---|
| Legal Definition | Not defined in Education Code; term refers to locally funded charters (EC Section 47651) | Direct-funded charter school receiving funds directly from the state (EC Section 47651) |
| Also Known As | Affiliated charter, district-operated charter, locally funded charter | Direct-funded charter, nonprofit charter |
| Typical Origin | Created by district/county; conversion of existing school, or district meeting a community need | Petition submitted by teachers, parents, or community members; nonprofit organization |
| Legal Entity | Not a separate legal entity; operates as part of the district/county | Typically a 501(c)(3) nonprofit corporation separate from the authorizer |
Governance
| Aspect | Dependent Charters | Independent Charters |
|---|---|---|
| Governing Board | Usually the authorizing district/county board serves as the charter governing board | Separate, independent governing board required |
| Board Meetings | Must distinguish between acting as authorizer vs. charter board (agenda, minutes) |
Separate board meetings; Brown Act compliance required |
| Advisory Bodies | May have advisory council or governance committee; not a governing board | May have advisory committees; governing board has final authority |
| Autonomy | Limited; EC Section 47601 requires independence, but board overlap creates complexity |
Full operational autonomy within charter terms and applicable law |
Employees and Staffing
| Aspect | Dependent Charters | Independent Charters |
|---|---|---|
| Employment Status | Employees of the district/county; subject to district HR policies | Employees of the charter school or its nonprofit; separate employer |
| Collective Bargaining | District collective bargaining agreement (CBA) typically applies; transfer provisions may apply | May have separate bargaining unit or be non-union; charter determines |
| Salary and Benefits | Usually follows district salary schedules and benefit packages | Charter establishes own compensation structure |
| Retirement System | Charter establishes own compensation structure | Charter selects |
| Staff Transfers | CBA and petition govern; district employees may resist forced transfer to charter |
No transfer provisions with authorizer; separate hiring process |
Finances
| Aspect | Dependent Charters | Independent Charters |
|---|---|---|
| Funding Flow | Indirect/locally funded: funds pass through district or county (EC Section 47651) | Direct funded: receives apportionment directly from the state |
| Fund Accounting | Best practice: separate Fund 09; commingling is a common problem |
Maintains own accounts, typically in Fund 09 or Charter Fund 62 |
| In-Lieu Taxes | Pass-through funding should be recorded separately (EC Section 47651[a][2]) | Receives directly or through authorizer, per agreement |
| Annual Audit | Included in district audit; auditor stratifies sample and applies charter compliance procedures | Independent annual audit required; submitted to authorizer and CDE |
| Oversight Fee | Up to 1 percent (EC Section 47613); may purchase additional services beyond fee | Up to 1 percent for actual oversight costs (EC Section 47613) |
| Grant Eligibility | May be restricted; cannot be 501(c)(3), so some grants unavailable | 501(c)(3) status enables broader grant eligibility |
Oversight and Compliance
| Aspect | Dependent Charters | Independent Charters |
|---|---|---|
| Oversight Duty | Full oversight required per EC Section 47604.32, despite operational relationship | Full oversight required per EC Section 47604.32 |
| Authorizer Liability | EC Section 47604(c) ties liability to oversight performance; arms-length relationship required |
EC Section 47604(c) liability protection linked to oversight; EC Section 47604(d) may apply |
| LCAP Requirements | Separate LCAP required; not part of district LCAP; same process requirements | Separate LCAP required; authorizer reviews and approves |
| Reporting Calendar | Same deadlines: Budget/LCAP by July 1; Interims by Dec. 15 and Mar. 15; Unaudited Actuals by Sept. 15 |
Same deadlines, per EC Section 47604.33 |
| MOU/Agreement | Different format; may not be traditional MOU, given unified governance | Comprehensive MOU typical; addresses operational relationship |
Operations
| Aspect | Dependent Charters | Independent Charters |
|---|---|---|
| Policies and Procedures | Often subject to all district policies and procedures | Adopts own policies; petition governs required elements |
| Student Information System (SIS) | May be required to use same SIS as authorizer | Selects own SIS; must meet state reporting requirements |
| School Calendar | May have calendar restrictions aligned with district | Sets own calendar within instructional minutes requirements |
| Procurement | May be restricted to authorizer Request for Qualifications/Request for Proposal vendors | Independent procurement; follows own policies and applicable law |
| Facilities | Relatively more flexibility; may share district facilities | Prop 39 rights; may lease or own facilities independently |
| Legal Counsel | One entity for legal purposes; district counsel represents | Engages own legal counsel; separate representation |
Renewal and Revocation
| Aspect | Dependent Charters | Independent Charters |
|---|---|---|
| Renewal Process | Standard renewal criteria apply; complexity when district operates underperforming charter | Standard renewal criteria per EC Section 47607; performance-based |
| Material Revision | Same requirements; authorizer must determine what constitutes material change | Same requirements per EC Section 47607 |
| Closure Process | Must follow closure procedures; may be more complex due to integrated operations |
Follows closure procedures; nonprofit dissolution, if applicable |
Additional Resources
- Sacramento City Unified School District Sample Dependent Charter MOU
- CASI Quarterly Trainings: Training Materials and Resources
CASI Quarterly Training resources include information related to many of the topics mentioned during this training, such as oversight, facilities, renewals, and more.
Return to Quarterly Trainings
Return to Charter Authorizer Support Initiative